What Is the EPA RRP Rule—and When Do You Need LeadCheck?

If you’re working on a home or childcare facility built before 1978, there’s a high likelihood the paint contains lead—a hazardous substance, particularly for children. The EPA’s Renovation, Repair, and Painting (RRP) Rule was established to safeguard families and workers by enforcing safe renovation practices. If you’re a contractor, landlord, or property manager, this rule applies to you—and LeadCheck is the quick, reliable tool to help you comply.

Understanding the EPA’s Renovation, Repair and Painting (RRP) Rule

The EPA’s RRP Rule mandates that any renovation, repair, or painting work that disturbs painted surfaces in pre-1978 “target housing” or “child-occupied facilities” must adhere to lead-safe practices. This rule, fully effective since April 2010, applies to:

• Contractors and tradespeople (painters, electricians, plumbers, etc.)
• Landlords performing maintenance on rental properties
• House flippers and rehabbers
• Property managers and maintenance staff

Jobs covered by this rule include window replacements, sanding, scraping, and demolition. Violations can lead to penalties up to $44,792 per day, per violation under the Toxic Substances Control Act (TSCA). Repeated offenses or deliberate non-compliance can also result in court-ordered abatement work, loss of licensing, and reputational damage. Some contractors have even been ordered to perform community remediation projects or pay restitution for unsafe practices.

Does This Apply to You?

Covered Projects

If you disturb painted surfaces in homes, apartments, schools, or daycare centers built before 1978, you’re likely covered by this rule.

Who Must Comply

Anyone paid to do renovation work, including contractors, subcontractors, landlords, or house flippers, must comply.

Exemptions

• Homeowners working on their own occupied homes (with no tenants or daycare use)
• Minor repairs disturbing less than 6 sq ft per room (interior) or less than 20 sq ft (exterior)
• Certified lead-free housing, verified by an EPA-certified inspector

What Does RRP Compliance Involve?

To stay compliant, you must:

• Be an EPA-Certified Firm
• Use at least one Certified Renovator per job
• Distribute the “Renovate Right” pamphlet to occupants before work begins
• Follow lead-safe work practices: contain the workspace, avoid high-dust methods, use HEPA-filtered vacuums, and protect occupants
• Perform cleaning verification using EPA standards or conduct clearance testing
• Maintain detailed records for 3 years, including test results, training certifications, and signed acknowledgments

The Role of Lead Testing in RRP Compliance

Contractors have two options:

1. Assume lead is present and follow all RRP protocols on disturbed surfaces.
2. Test surfaces using an EPA-recognized method. If a surface is certified lead-free, RRP requirements can be waived for that component.

This is where LeadCheck becomes an essential part of your workflow.

When Is LeadCheck Used?

LeadCheck is used before renovation work begins to determine if lead paint is present. It’s ideal for:

• Walls, trim, doors, windows, and other painted surfaces
• Jobs where you want to limit RRP compliance to only lead-positive areas
• Documenting testing results for your EPA-required project records

If LeadCheck confirms no lead is present, you can proceed without full containment and other RRP steps for that surface.

Why Choose LeadCheck?

LeadCheck Swabs are trusted by contractors nationwide because they’re:

• EPA-recognized for use on wood, drywall, plaster, and ferrous metal
• Fast – results in just 30 seconds
• Simple – no lab equipment or special training needed
• Reliable – consistent and accurate results with no shelf-life
• Cost-saving – rule out lead on certain surfaces and reduce compliance burdens

What Happens If You Don’t Comply?

Non-compliance with the RRP Rule can lead to serious consequences:

• Fines of up to $44,792 per violation per day
• Mandatory community abatement or lead hazard reduction projects
• Legal action, license suspension, and damage to your business reputation

Real-World Example: Logan Square Aluminum Supply

In one major case, a Chicago-based window replacement company was found to have performed renovations on over 40 homes and a childcare facility without following RRP protocols. Violations included:

• No containment or dust control
• Use of uncertified workers
• No distribution of Renovate Right pamphlets
• No testing or documentation

The result? A $2 million court-ordered lead abatement program and a $400,000 civil penalty. This case highlights that the EPA takes enforcement seriously, especially in projects that impact families with children.

A Brief History of the RRP Rule

• 1992: Congress passes the Residential Lead-Based Paint Hazard Reduction Act (Title X)
• 2008: EPA issues the final RRP Rule
• April 2010: RRP Rule goes into effect nationwide
• 2010: EPA removes the controversial “opt-out” provision
• 2015–2021: Clearance standards and dust-lead hazard levels are lowered
• 2024: EPA proposes additional post-renovation clearance requirements to strengthen protections

The RRP Rule continues to evolve as science advances and awareness of lead poisoning grows. LeadCheck remains a key tool in helping contractors adapt to these regulatory changes.